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Permanent establishment issues paper


This paper focusses on the central role played by PE in Australian international tax law, including:

  • the impact for Australian businesses operating offshore through a PE, including the ability of foreign countries to tax the PE operations, the ability to claim foreign tax credits in Australia for foreign taxes as well as recent changes to the Australian tax treatment of foreign branch income and the quarantining of foreign source deductions
  • what is required for an overseas entity to have a taxable Australian PE under Australian domestic law and as a result of various tax treaties entered into with other countries
  • if a PE exists, what does it mean for the overseas entity (ie registering for income tax, lodging income tax returns etc), non-resident contractors etc.
  • the interaction between Australian domestic tax law and tax treaties, including a detailed discussion of recent case law and the varying implications depending upon the country of residence of the overseas entity.

Author profile

Mathew Chamberlain CTA
Mathew is a partner at EY and leads their Perth International Tax group. A legal practitioner admitted in WA and NSW, he has more than 27 years’ experience in international tax, focusing on the large multinational and corporate environments across Australia, the US, Europe, Asia-Pacific and Africa. Mathew specialises in international tax reform, foreign investment into Australia and outbound investment from Australia. A long-time member of The Tax Institute, Mathew has presented at numerous national and state conventions on international tax issues and has also lectured on tax law at the University of Western Australia and Curtin University. Mathew has led and participated in a number of government and ATO initiatives, working groups etc. on international tax law and policy issues affecting Australian inbound and outbound investment, including through the development of professional body and EY submissions on tax residency. - Current at 30 November 2020
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